3 replies to this topic

[Patricia326]

I have a question regarding allergen stickers on our pallets.  We do not have allergens in our manufacturing process, but we do have items we purchase and distribute that do contain allergens.  They always remain enclosed but we do store them in the warehouse using allergen storage guidelines.  We have a procedure for cleaning up allergens should there be a forklift accident or something else that would cause the allergens to spill.  My question is - what if the allergen in the ingredients is declared, then underneath there is a statement that says it may contain an additional allergen such as soy because lines are shared?  Does that mean I would label the pallet with the allergen ingredient AND the potential allergen (such as soy) that is not an ingredient but used on shared lines?  Currently I am counting the soy as an allergen as well although it is not specifically and ingredient in the product.  Is this overkill or am I reporting correctly?

 

Patricia 

[Scampi]

The general rule of thumb is that poor GMPs should not be the reason a "May contain" statement is applied to packaging

 

So if you have sound policies (and it sounds like a yes) then you do not have to declare the allergen that you only distribute

[jfrey123]

If I'm understanding, you've got finished good you distribute only and those items state "Contains: An Allergen - May contain a different allergen"

 

I would not sticker/label the finished good with the 'may contain' allergen.  It shouldn't contain that allergen (you used soy as the may contain example), so labeling it with soy stickers and stacking it amongst soy is introducing a hazard to those items that don't contain soy.  May contain is a craptastic attempt to be a catch-all to cover a company's butt if the sanitation is lacking, but it doesn't carry much efficacy.

[Tony-C]

Hi Patricia326,

 

As per previous posts I would only label the ones with confirmed allergen status and apply your allergen clean up procedures to those. If you have sound ‘clean as you go’ policies and clean up any other spillages I wouldn’t worry too much unless you are storing open products.

 

jfrey123, that is my word of the day: craptastic     

 

As you and Scampi have implied ‘may contain’ is overused and should be fully justified.

 

Kind regards,

 

Tony